CUNA Regulatory Comment Call

July 13, 2009

NCUA Interim Final Rule to Provide Exception to the Maturity Limit on Second Mortgages

EXECUTIVE SUMMARY

The NCUA Board approved an interim final rule to amend its lending rules to create a limited exception to the
20-year maturity limit on second mortgage loans. The amendment will allow federal credit unions that are taking part
in the Treasury Departments Making Home Affordable (MHA) Program to extend second mortgages beyond 20 years in order
to match the term of a modified first mortgage.

The MHA Program is intended to help homeowners facing foreclosure by modifying their mortgages so that the payments
are more affordable. The Program also includes incentives for lenders to modify second mortgages held by the homeowner,
which requires the lender to extend the term of the second mortgage to match the term of the first.

NCUA's lending rules currently limit first mortgage loans to 40 years and second loans to 20. The amendment will
create an exception to the 20 year limit for federal credit unions participating in the MHA Program.

The rule is effective as of June 24, 2009, and NCUA will accept comments until August 24, 2009. Please submit your
comments to CUNA by August 12, 2009.

Please feel free to fax your responses to CUNA at 202-638-7052; e-mail them to Senior Vice President and Deputy General
Counsel Mary Dunn at mdunn@cuna.com and to Senior Assistant General Counsel Jeff Bloch at
jbloch@cuna.com; or mail them to Mary and Jeff in c/o CUNAs Regulatory Advocacy Department, 601
Pennsylvania Avenue, NW, South Building, Suite 600, Washington, DC 20004-2601. You may also contact us at 800-356-9655, ext.
6032, if you would like a copy of the interim final rule, or you may access it
here.

QUESTIONS TO CONSIDER REGARDING NCUAs INTERIM FINAL RULE

Do you support the interim final rule? Should it apply to all modifications, not just
modifications under the MHA? Should the currently maturity limit be removed permanently for
all second mortgages?